Wagner's widely publicized association of mesothelioma with Cape Crocidolite asbestos exposure created the potential for the introduction of diagnostic bias (Wagner, i960 ).

If any piece of equipment which was used at any time to install, cut, shape, etc. products identified in answer to interrogatory no. 1 or 7(b) was invented, -7- developed or first made by answering defendant or any person associated with you or any related company or association, state: (a) When it was invented, developed or made (including changes or improvements to previously available equipment); (b) The identity of each individual who participated therein and describe in detail the extent of his participation; (c) The identity of each document which reflects, refers or relates to any information set forth in answer to this interrogatory.

Wagner's widely publicized association of mesothelioma with Cape Crocidolite asbestos exposure created the potential for the introduction of diagnostic bias (Wagner, i960).

Dept, of Commerce, Bureau of the Census, 1971) were assign ed to the employment information ascertained from medical histories, death certificates, and City Directories.

If you manufacture any insulation products which are commonly used by insulators and which contain asbestos; (a) Describe how the products listed in (b) are cut, shaped, mixed and applied on the jobs giving particular reference as to whether or not the materials have to be sawed or cut on the job, blown into confined areas, or mixed with water into a cement or paste; (b) State if ther is any way known to you that the produ^ listed below can be used and applied without the worker inhaling any of the asbestos dust or fibers: (1) Asbestos cement; Asbestos Finishes;. (2) Asbestos pipe covering; (3) Asbestos bricks or block; (4) Asbestos sheeting; (5) Asbestos insulation used to cover extremes of heat as well as cold; (6) Asbestos insulation in loose form which may be blown into hones or buildings; (7) Asbestos in spray form; (8) Asbestos mineral in fiber form or particulate fonr (9) Asbestos Millboard, rope, gaskets, paper gloves or blanket.

(2) Asbestos pipe covering; (3) Asbestos bricks or block;

-'Concentration lj`11 <r^1 P'*** '~"K<" / 'w foot had asbestos!

A former subsidiary of Manville, Johns-Manville Canada, Inc., tested and graded chrysotile asbestos by a method instituted by the Quebec Asbestos Mining Association* which gained worldwide acceptance as a standard for the classification and evaluation of chrysotile fiber.

r NOON & PRATT 7 1 asbestos fiber. 2 Q Does the mining and milling take place 3 .

The district mechanics are mem- bers of the International Association of Machinists & Aerospace Workers (lAM), Marin County lodge No. 238.

PLAINTIFF'S EXHIBIT A(3 FRCW A/C Pipe `ydie-d mtemaf Correspondence Producers Association Executive Committee International Affairs Committee /0Q'^.UXelc.Llp j/lj.

Dow objects to any discovery request seeking information pertaining to any subsidiary and/or other business association, that was not a subsidiary and/or business association at the relevant time periods, and which continues to exist as a separate legal entity(ies). 11.

Subject to these objections, Dow asserts it is unable to pinpoint a precise date on which it, as a corporate entity, affirmatively knew of an association between asbestos exposure and disease as medical and scientific literature regarding asbestos related disease developed gradually over time.

Subject to these objections, Dow asserts it is unable to pinpoint a precise date on which it, as a corporate entity, affirmatively knew of an association between asbestos exposure and disease as medical and scientific literature regarding asbestos related disease developed gradually over time.

Subject to these objections, Dow asserts it is unable to pinpoint a precise date on which it, as a corporate entity, affirmatively knew of an association between asbestos exposure and disease as medical and scientific literature regarding asbestos related disease developed gradually over time.